Jada wants to transfer some assets to a trust this year; the

income beneficiaries will be her two grandchildren. The trust

income and assets will be used to pay the grandchildren$$s tuition

to private high schools and universities. Upon the younger

grandchild$$s graduation, the trust assets will return to Jada$$s

ownership. Identify tax issues related to Jada$$s plan to use a

temporary fiduciary entity.